American Waterways Operators, Inc. v. Askew

335 F. Supp. 1241, 3 ERC 1429, 2 Envtl. L. Rep. (Envtl. Law Inst.) 20072, 3 ERC (BNA) 1429, 1971 U.S. Dist. LEXIS 10418
CourtDistrict Court, M.D. Florida
DecidedDecember 10, 1971
Docket71-156-Civ.-J
StatusPublished
Cited by11 cases

This text of 335 F. Supp. 1241 (American Waterways Operators, Inc. v. Askew) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Waterways Operators, Inc. v. Askew, 335 F. Supp. 1241, 3 ERC 1429, 2 Envtl. L. Rep. (Envtl. Law Inst.) 20072, 3 ERC (BNA) 1429, 1971 U.S. Dist. LEXIS 10418 (M.D. Fla. 1971).

Opinion

MEMORANDUM OPINION AND FINAL JUDGMENT

Before RONEY, Circuit Judge, and SCOTT and TJOFLAT, District Judges.

TJOFLAT, District Judge:

During the 1970 session the Florida Legislature passed the “Oil Spill Prevention and Pollution Control Act” 1 (hereinafter called the “Florida Act”) in an attempt to prevent pollution by the shipping industry of waters within the territorial jurisdiction of the State of Florida. The Act imposes unlimited liability without fault upon virtually any vessel which discharges oil or any other pollutant while destined for or leaving any Florida port. 2 Onshore and offshore *1243 terminal facilities are subject to the same liability. 3 The Act requires every owner or operator of a vessel using a Florida port or a terminal facility to pay whatever cleanup costs or damages may result from the discharge of pollutants 4 and to maintain satisfactory evidence of financial responsibility to satisfy such liability. 5 The Department of Natural Resources is empowered to *1244 require any vessel transporting a pollutant in state waters to be equipped with specified containment gear and a crew trained in its use. 6 Prior to entering a Florida port, every vessel is subject to inspection by the port manager to determine the presence of the required containment gear and the seaworthiness of the ship. 7 He is required to notify all other ports in the state of any vessel refused entry to his port. 8

Plaintiffs and intervenors include merchant shippers whose vessels use Florida ports in the course of transporting goods in foreign and interstate commerce; world shipping associations who insure three-fourths of the ocean-going tonnage against, among other things, liability for oil spillage; a substantial portion of the barge and towing industry operating along the Florida coast; and owners of oil terminal facilities located in Florida ports. They have challenged the validity of the Florida Act on several federal constitutional grounds. Plaintiffs’ initial contention is that Florida has sought to legislate substantive maritime law which, under the United States Constitution, is exclusively within the federal domain. Secondly, *1245 they contend that the Act violates the Commerce Clause, since it seeks to regulate foreign and interstate commerce. Certain provisions of the Act are under piecemeal attack on Fourteenth Amendment due process and equal protection grounds. The resolution of the first of these contentions dictates the decision in this case, and the others will not be discussed.

The maritime law of the United States has evolved under Article 3, Section 2, of the Constitution which extends the judicial power of the United States “to all Cases of admiralty and maritime Jurisdiction.” In a territorial sense that jurisdiction covers all waters navigable in interstate or foreign commerce, including state waters. 9 Maritime law governs virtually every facet of the shipping industry from the design and construction of vessels to the regulation of their day to day operations and the transactions in which they engage. It comprises traditional admiralty rules and concepts found initially in the European authorities. These rules and concepts have been augmented from time to time by the federal judiciary to accommodate needs distinctive to this nation. Further changes in the corpus of maritime law have been effected by a variety of congressional enactments and administrative regulations. 10 One of these congressional enactments is the Water Quality Improvement Act of 1970 11 (hereinafter called “W.Q.I.A.”) which became law a few months prior to the effective date of the Florida Act. W.Q. I. A. provides plaintiffs with tangible evidence that the Florida Act is an unconstitutional intrusion into the federal maritime domain.

The W.Q.I.A. reinforces the national anti-water pollution policy. In this act Congress declared that there should be no discharge of oil into or upon the navigable waters and shorelines of the United States. 12 The owner or operator of a vessel or an onshore or offshore facility is subject to limited liability without fault for the costs expended by the government in cleaning up an oil spill. 13 Where the spillage results from willful negligence or misconduct, however, liability for such costs can be unlimited. 14 Evidence of financial responsibility sufficient to cover its potential liability must be given by any vessel of 300 gross tons or more that uses the navigable waters of the United States. 15 Additionally, the President is authorized to issue regulations requiring, among other things, that vessels maintain oil spill prevention equipment and be subject to boarding for inspection purposes at any time. 16

In adopting W.Q.I.A. Congress anticipated that all hazardous substances, in addition to oil, capable of polluting navi *1246 gable waters would be subject to similar legislative treatment. 17 W.Q.I.A. required the President to promulgate regulations defining such hazardous substances and establishing methods and means for their removal. 18 He was also required to report to Congress, by November 1, 1970, on the desirability of enacting legislation to establish liability for the cost of removing hazardous substances discharged from vessels and onshore and offshore facilities. 19

That the Florida Act constitutes unlawful intrusion into the exclusive federal admiralty domain is apparent when one observes the extent to which that act would change substantive maritime law. The most obvious changes would be in the liability now imposed by W.Q. I.A. and maritime rules on shippers and the operators of onshore and offshore facilities.

While both W.Q.I.A. and the Florida Act subject vessels and onshore and offshore facilities to strict liability for cleanup costs, the latter imposes a far greater measure of responsibility. For example, W.Q.I.A. would excuse a shipper who demonstrates that the oil spill was caused by act of God, an act of war, or the act or omission of a third party. 20 The Florida Act recognizes none of these defenses to a claim by the state for cleanup costs.

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Related

United States v. Dixie Carriers, Inc.
462 F. Supp. 1126 (E.D. Louisiana, 1978)
United States v. M/V BIG SAM
454 F. Supp. 1144 (E.D. Louisiana, 1978)
County of Clark v. City of Las Vegas
550 P.2d 779 (Nevada Supreme Court, 1976)
People v. Texaco, Inc.
81 Misc. 2d 260 (Nassau County District Court, 1975)
Askew v. American Waterways Operators, Inc.
411 U.S. 325 (Supreme Court, 1973)
Portland Pipe Line Corp. v. Environmental Improvement Commission
307 A.2d 1 (Supreme Judicial Court of Maine, 1973)
Mobil Oil Corp. v. Town of Huntington
72 Misc. 2d 530 (New York Supreme Court, 1972)

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Bluebook (online)
335 F. Supp. 1241, 3 ERC 1429, 2 Envtl. L. Rep. (Envtl. Law Inst.) 20072, 3 ERC (BNA) 1429, 1971 U.S. Dist. LEXIS 10418, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-waterways-operators-inc-v-askew-flmd-1971.